The County Court granted summary judgment to the Deputy Commissioner of Taxation for an RBA deficit debt of $599,969.63, holding that the defendant failed to displace the prima facie evidential force of the RBA statement and Commissioner's certificate under ss 8AAZI and 8AAZJ of the TAA53. The Court held that bare assertions of errors in prior proceedings, unparticularised complaints about discrepancies between audit documents and the RBA, and challenges to GST assessment quantum were insufficient to raise a real prospect of success, particularly where the Commissioner had already reviewed the RBA and addressed the defendant's concerns, and where challenges to GST assessments must be brought under Part IVC of the TAA53 rather than in debt recovery proceedings.
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